ML042110156

R. E. Ginna Nuclear Power Plant, Application for Technical Specification Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports

ML042110156
Person / Time
Site:	Ginna
Issue date:	07/26/2004
From:	Korsnick M Constellation Energy Group
To:	Clark R Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML042110156 (15)

Text

Maria Korsnick 1503 Lake Road Vice President Ontario, New York 14519-9364 585.771.3494 585.771.3943 Fax mara.korsnick @constellation.com Constellation Energy R.E. Ginna Nuclear Power Plant July 26, 2004 Mr. Robert L. Clark Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Application For Technical Specification Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports R. E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Clark:

In accordance with the provisions of 10 CFR 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) is submitting a request for an amendment to the Technical Specifications (TS) for the R.E. Ginna Nuclear Power Plant.

The proposed amendment would delete the TS requirements to submit monthly operating reports and occupational radiation exposure reports. The change is consistent with NRC approved Revision 1 to industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-369, "Removal of Monthly Operating Report and Occupational Radiation Exposure Report." The availability of this TS improvement was announced in the Federal Register on June 23, 2004 (69 FR 35067) as part of the consolidated line item improvement process (CLUIP).

Enclosure 1 provides a description of the proposed change and the requested confirmation of applicability. Enclosure 2 provides the existing TS pages marked-up to show the proposed change. Enclosure 3 provides the revised (clean) TS pages. Enclosure 4 provides a summary of the regulatory commitments made in this submittal.

Ginna LLC requests approval of the proposed license amendment by February 1, 2005 with the amendment being implemented within 60 days.

I6OAOD

In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated New York State Official.

Any questions concerning this submittal should be directed to Thomas Harding, Nuclear Safety and Licensing at (585) 771-3384.

Very truly yo Mary Korsnick

Enclosures:

1. Description and Assessment

2. Proposed Technical Specification Changes (markup)

3. Revised Technical Specification Pages

4. List of Regulatory Commitments STATE OF NEW YORK:

TO WIT:

COUNTY OF WAYNE :

I, Mary G. Korsnick, being duly sworn, state that I am Vice President - R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC), and that I am duly authorized to execute and file this response on behalf of Ginna LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my and I believe it to be reliable. ( / n f1.

personal knowledge, they are based upon information provided by other Ginna LLC employees and/or consultants. Such information has been reviewed in accordance with company practice Subscribed anyd i before me, a Notary Public in d o the State of New York and County of , this,2( dayof t-uW, 2004.

WITNESS my Hand and Notarial Seal:

Notary Public My Commission Expires: -e2-Dat )

Date 9"R~ZL LAI MILER

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xc: Mr. Robert L. Clark (Mail Stop 0-8-C2)

Project Directorate I Division of Licensing Project Management Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U.S. NRC Ginna Senior Resident Inspector James M. Petro Jr., Esquire Counsel Constellation Energy 750 East Pratt Street, 5th Floor Baltimore, MD 21202 Mr. Peter R. Smith New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul D. Eddy Electric Division NYS Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223 Daniel F. Stenger Ballard Spahr Andrews & Ingersoll, LLP 601 13 th Street, N.W., Suite 1000 South Washington, DC 20005

Enclosure 1 R.E. Ginna Nuclear Power Plant Description and Assessment

1.0 INTRODUCTION

The proposed License amendment deletes the requirements in Technical Specification (TS) 5.6.1 for an annual report on occupational radiation exposures and TS 5.6.4 for a monthly report of operating statistics and shutdown experience. The changes are consistent with NRC approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-369, "Removal of Monthly Operating Report and Occupational Radiation Exposure Report," Revision 1. The availability of this technical specification improvement was announced in the Federal Register on June 23, 2004 (69 FR 35067), as part of the consolidated line item improvement process (CLiIP).

2.0 DESCRIPTION

OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision 1 of TSTF-369, the proposed TS changes include:

TS 5.6.1 Occupational Radiation Exposure Report Deleted TS 5.6.4 Monthly Operating Reports Deleted As addressed in the safety evaluation published in the Notice of Availability for TSTF-369, Ginna LLC is proposing to adopt a part of NRC-approved Revision 4 to TSTF-258, "Changes to Section 5.0, Administrative Controls." Specifically, TS 5.6.4 includes a requirement to include in the monthly operating reports any challenges to pressurizer power operated relief valves or pressurizer safety valves. The NRC model safety evaluation addressed the removal of requirements to submit monthly operating reports in those cases where the TS includes a requirement to address challenges to relief and safety valves. The proposed change is consistent with the option described in the Notice of Availability published on June 23, 2004 (69 FR 35067) and the related documentation for both TSTF-369 and the limited portion of TSTF-258 included in this application.

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369.

4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369.

5.0 TECHNICAL ANALYSIS

Ginna LLC has reviewed the safety evaluation (SE) published on June 23, 2004 (69 FR 35067) as part of the CLUP Notice of Availability. This verification included a review of the NRC staffs SE and the supporting information provided to support TSTF-369. Ginna LLC has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to the R.E. Ginna Nuclear Power Plant and justify this amendment for the incorporation of the changes to the TS.

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369.

6.1 Verification and Commitments As discussed in the model SE published in the Federal Register on June 23, 2004 (69 FR 35067) for this TS improvement, Ginna LLC is making the following regulatory commitments:

1. Ginna LLC is making a regulatory commitment to provide to the NRC using an industry database the operating data (for each calendar month) that is described in Generic Letter 97-02 "Revised Contents of the Monthly Operating Report," by the last day of the month following the end of each calendar quarter. The regulatory commitment will be based on use of an industry database (e.g., the industry's Consolidated Data Entry (CDE) program, currently being developed and maintained by the Institute of Nuclear Power Operations).

This regulatory commitment will be implemented to prevent any gaps in the monthly operating statistics and shutdown experience provided to the NRC (i.e., data for all months will be provided using one or both systems (monthly operating reports and CDE)).

2. R.E. Ginna Nuclear Power Plant does not have different reactor types or both operating and shutdown reactors.

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION Ginna LLC has reviewed the proposed no significant hazards consideration determination published on June 23, 2004 (69 FR 35067) as part of the CLIIP. Ginna LLC has concluded that the proposed determination presented in the notice is applicable to the R.E. Ginna Nuclear Power Plant and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

8.0 ENVIRONMENTAL EVALUATION Ginna LLC has reviewed the environmental evaluation included in the model SE published on June 23, 2004 (69 FR 35067) as part of the CLIIP. Ginna LLC has concluded that the staffs findings presented in that evaluation are applicable to the R.E. Ginna Nuclear Power Plant and the evaluation is hereby incorporated by reference for this application.

9.0 PRECEDENT This application is being made in accordance with the CLIIP. Ginna LLC is not proposing variations or deviations from the TS changes described in TSTF-369 and the limited portion of TSTF-258 or the NRC staff's model SE published on June 23, 2004 (69 FR 35067).

10.0 REFERENCES

Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specifications Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Using the Consolidated Line Item Improvement Process, published June 23, 2004 (69 FR 35067).

Enclosure 2 R.E. Ginna Nuclear Power Plant Proposed Technical Specification Changes (markup)

Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.6.1

( A tabulation on an annua asis of the number of station, tility, and other

> eWe1<!A r \

}

personnel (including co ~rctors) receiving exposures >00 mrem/yr and their associated man m exposure according to wo and job functions (e.g., reactor operatj ns and surveillance, inservice spection, routine maintenance, spe al maintenance, waste proce ng, and refueling).

! This tabulation s pplements the requirements of 0 CFR 20.2206. The dose assignm ts to various duty functions m be estimated based on pocket dosi ter, thermoluminescent dosim er (TLD), or film badge measurem ts. Small exposures totalling 20% of the Individual total dose ne not be accounted for. In the a gregate, at least 80% of the total w le body dose received from ext nal sources should be assigned to sp ific major work functions. The port shall be submitted on or bef e April 30 of each year.

5.6.2 Annual Radioloalcal Environmental peratinci Revort The Annual Radiological Environmental Operating Report covering the operation of the plant during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the radiological environmental monitoring activities for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and In 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted In a supplementary report as soon as possible.

R.E. Ginna Nuclear Power Plant 5.6-1 Amendment 91

Reporting Requirements 5.6 5.6.3 Radioactive Effluent Release Renort The Radioactive Effluent Release Report covering the operation of the plant shall be submitted In accordance with 10 CFR 50.36a. The report shall Include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the plant. The material provided shall be consistent with the objectives outlined in the ODCM and In conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.

5.6.4 r onth ODertn Repo Routine reports of optng statistics and shutw experiene including do uZ~ton of all challenges toi prsuier power oeated rel-0igum or pressurizer saeviesshl be submited on )

a mnthass n lter than the I15th Bach month following the re b her 5.6.5 CORE OPERATING LIMITS REPORT (COLR)

The following administrative requirements apply to the COLR:

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

LCO 3.1.1, 'SHUTDOWN MARGIN (SDMr; LCO 3.1.3. 'MODERATOR TEMPERATURE COEFFICIENT (MTC)r; LCO 3.1.5, 'Shutdown Bank Insertion Umit";

LCO 3.1.6, 'Control Bank Insertion Limits";

LCO 3.2.1, 'Heat Flux Hot Channel Factor (Fr(Z))';

LCO 3.2.2, 'Nuclear Enthalpy Rise Hot Channel Factor (FN ,H)";

LCO 3.2.3, -AXIAL FLUX DIFFERENCE (AFD)r; LCO 3.4.1, 'RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Umits'; and LCO 3.9.1, 'Boron Concentration.'

R.E. Ginna Nuclear Power Plant - 5.6-2 Arrendments

Enclosure 3 R.E. Ginna Nuclear Power Plant Revised Technical Specification Pages

Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted In accordance with 10 CFR 50.4.

5.6.1 Deleted 5.6.2 Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report covering the operation of the plant during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the radiological environmental monitoring activities for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

5.6.3 Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the plant shall be submitted In accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the plant. The material provided shall be consistent with the objectives outlined in the ODCM and In conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.

5.6.4 Deleted R.E. Ginna Nuclear Power Plant 5.6-1 Amendment

Reporting Requirements 5.6 5.6.5 CORE OPERATING LIMITS REPORT (COLR)

The following administrative requirements apply to the COLR:

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented In the COLR for the following:

LCO 3.1.1, 'SHUTDOWN MARGIN (SDM)";

LCO 3.1.3, NMODERATOR TEMPERATURE COEFFICIENT (MTC)O; LCO 3.1.5, 'Shutdown Bank Insertion Limit';

LCO 3.1.6, 'Control Bank Insertion Limits";

LCO 3.2.1, 'Heat Flux Hot Channel Factor (F0 (Z))';

LCO 3.2.2, "Nuclear Enthalpy Rise Hot Channel Factor (FNAH)N; LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)';

LCO 3.4.1, "RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits"; and LCO 3.9.1, "Boron Concentration."

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

1. WCAP-9272-P-A, Westinghouse Reload Safety Evaluation Methodology," July 1985.

(Methodology for LCO 3.1.1, LCO 3.1.3, LCO 3.1.5, LCO 3.1.6, LCO 3.2.1, LCO 3.2.2, LCO 3.2.3, and LCO 3.9.1.)

2. WCAP-13677-P-A, "10 CFR 50.46 Evaluation Model Report:

WCOBRA/TRAC Two-Loop Upper Plenum Injection Model Updates to Support ZIRLOTM Cladding Option," February 1994.

(Methodology for LCO 3.2.1.)

3. WCAP-8385, "Power Distribution Control and Load Following Procedures - Topical Report," September 1974.

(Methodology for LCO 3.2.3.)

4. WCAP-1 2610-P-A, "VANTAGE + Fuel Assembly Reference Core Report," April 1995.

(Methodology for LCO 3.2.1.)

R.E. Ginna Nuclear Power Plant 5.6-2 Amendment

Reporting Requirements 5.6

5. WCAP 11397-P-A, 'Revised Thermal Design Procedure,"

April 1989.

(Methodology for LCO 3.4.1 when using RTDP.)

6. WCAP-1 0054-P-A and WCAP-1 0081 -A, "Westinghouse Small Break ECCS Evaluation Model Using the NOTRUMP Code,' August 1985.

(Methodology for LCO 3.2.1.)

7. WCAP-10924-P-A, Volume 1, Revision 1, 'Westinghouse Large-Break LOCA Best-Estimate Methodology, Volume 1:

Model Description and Validation Responses to NRC Questions," and Addenda 1,2,3, December 1988.

(Methodology for LCO 3.2.1.)

8. WCAP-10924-P-A, Volume 2, Revision 2, "Westinghouse Large-Break LOCA Best-Estimate Methodology, Volume 2:

Application to Two-Loop PWRs Equipped with Upper Plenum Injection," and Addendum 1, December 1988.

(Methodology for LCO 3.2.1.)

9. WCAP-1 0924-P-A, Volume 1, Revision 1, Addendum 4,

'Westinghouse Large-Break LOCA Best-Estimate Methodology, Volume 1: Model Description and Validation, Addendum 4: Model Revisions," March 1991.

(Methodology for LCO 3.2.1.)

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.6 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)

The following administrative requirements apply to the PTLR:

a. RCS pressure and temperature limits for heatup, cooldown, criticality, and hydrostatic testing as well as heatup and cooldown rates shall be established and documented in the PTLR for the following:

LCO 3.4.3, WRCS Pressure and Temperature (PIT) Limits' R.E. Ginna Nuclear Power Plant 5.6-3 Amendment

Reporting Requirements 5.6

b. The power operated relief valve lift settings required to support the Low Temperature Overpressure Protection (LTOP) System, and the LTOP enable temperature shall be established and documented in the PTLR for the following:

LCO 3.4.6, ORCS Loops - MODE 4';

LCO 3.4.7, ARCS Loops -MODE 5,Loops Filled";

LCO 3.4.10, Pressurizer Safety Valves"; and LCO 3.4.12, SLTOP System.'

c. The analytical methods used to determine the RCS pressure and temperature and LTOP limits shall be those previously reviewed and approved by the NRC in NRC letter, OR.E. Ginna - Acceptance for Referencing of Pressure Temperature Limits Report, Revision 2 (TAC No. M96529),' dated November 28,1997. Specifically, the methodology Is described In the following documents:

1. Letter from R.C. Mecredy, Rochester Gas and Electric Corporation (RG&E), to Document Control Desk, NRC, Attention: Guy S. Vissing, 'Application for Facility Operating License, Revision to Reactor Coolant System (RCS)

Pressure and Temperature Limits Report (PTLR)

Administrative Controls Requirements,' Attachment VI, September 29, 1997, as supplemented by letter from R.C.

Mecredy, RG&E, to Guy S. Vissing, NRC, "Corrections to Proposed Low Temperature Overpressure Protection System Technical Specification," October 8, 1997.

2. WCAP-1 4040-NP-A, 'Methodology used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves," Sections 1 and 2, January, 1996.

d. The PTLR shall be provided to the NRC upon Issuance for each reactor vessel fluence period and for revisions or supplement thereto.

R.E. Ginna Nuclear Power Plant 5.6-4 Amendment

Enclosure 4 R.E. Ginna Nuclear Power Plant List of Regulatory Commitments The following table identifies those actions committed to by R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Thomas Harding, Nuclear Safety and Licensing at (585) 771-3384.

REGULATORY COMMITMENT I DUE DATE Ginna LLC will provide to the NRC, using an Implemented with the amendment.

industry database, the operating data (for each calendar month) that is described in Generic Letter 97-02 "Revised Contents of the Monthly Operating Report," by the last day of the month following the end of each calendar quarter.